Questions and answers vat representation

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When will the change take effect? 

1 April 2017

Which countries does the change apply to?

This applies to NUFs with parent companies registered in Belgium, Denmark, Finland, France, Iceland, Italy, Malta, The Netherlands, Poland, Portugal, Slovenia, Spain, Great Britain, Sweden, Germany, Czech Republic, Bulgaria, Estonia, Faeroe Islands, Greenland, Greece, Croatia, Cyprus, Latvia, Lithuania, Romania, Slovakia and Hungary.

Has the country list been updated?

Yes, the country list was revised and expanded by 12 countries on 5 March 2017. The new countries are: Bulgaria, Estonia, Faeroe Islands, Greenland, Greece, Croatia, Cyprus, Latvia, Lithuania, Romania, Slovakia and Hungary.

What does this mean for enterprises from countries that are not included in the list?

Enterprises from other countries must continue to be registered through a representative who is jointly and severally liable for the payment of value added tax.

Do NUFs from countries on the list have to submit tax returns for VAT themselves?

You can still allow a representative to submit tax returns for VAT.

Accountants in Norway will also have authority.

Do I have to have a D number to submit tax returns for VAT?

Yes, as a foreign citizen you must have a D number in order to access Altinn.

If you submit a Coordinated register notification on paper, your application for a D number (BR1016) can be enclosed with the form.

If you use the Coordinated register notification in Altinn, your application for a D number (BR1016) must be submitted first, and then after the D number has been assigned you can report role changes in Altinn.

For further information, see Brønnøysund Register Centre website.

What happens if I do nothing?

Nothing changes. The representative will still be registered in the Register of Legal Entities and can submit tax returns for VAT.

Does the enterprise still have a bookkeeping obligation for VAT?

In accordance with Section 2 of the Bookkeeping Act, any entity obligated to submit tax returns for VAT in accordance with Section 8-3 of the Tax Administration Act has a bookkeeping obligation for the business operation. A foreign business with no place of business in Norway must still carry out bookkeeping that supports compulsory financial statements in Norway and document the posted information.

Must the accounts continue to be stored in Norway?

In accordance with Section 13, second paragraph of the Bookkeeping Act, accounting material shall be stored in Norway. This requirement applies even if the foreign business chooses not to have a VAT representative in Norway. 

Can an application for an exemption from the requirement to store accounts be submitted?

A taxable entity that chooses to not have a representative in Norway will, upon application, be permitted to store accounting material at the main company electronically. There will be a requirement for there to be access to electronic accounting material from Norway but there is no requirement to stipulate a location in Norway where such access is provided.

You can find more information here: http://www.skatteetaten.no/no/Radgiver/Rettskilder/Kunngjoringer/dispensasjon-fra-kravet-til-a-oppbevare-elektronisk-regnskapsmateriale-i-norge/

Where can I find information on the regulatory changes?

Prop. 113 L (2015-2016) “Changes to the Tax Assessment Act (extended access to direct registration)” which was submitted to the Storting (Norwegian Parliament) on 22 April 2016?

Where will I find the consultation document and the consultation statements?

The consultation document and relevant enclosures can be found here.

Where can I find information in English?

Here is the English website.

Can the first period be reported without a representative?

Yes, you can submit tax returns for VAT yourself if you wish to do so, including for the first period.

Are there changes to roles in Altinn?

The role of Contact person NUF will have the right to submit tax returns for VAT.

Can I register a foreign bank account number in Altinn?

With effect from 1.4.2017 (i.e. 2nd quarter) it is possible to register a foreign bank account number (with IBAN and BIC/SWIFT) on tax returns for VAT.

What is the difference between registering NUFs with or without a Norwegian business address?

No difference. A foreign company that establishes an NUF will have the same obligations and rights with or without a Norwegian business address.

Must the accounting system be adapted to SAFT?

It has not been determined at which point SAFT will become mandatory. When SAFT is introduced, NUFs will have to comply with it even if it is not a requirement in the home country.

When was the change in legislation formally passed?

The change was adopted in Council on 24.03.2017.

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